There are an increasing number of Americans who believe that the marginal benefit of surviving a few extra months is not worth the cost of suffering the pain, physical and/or mental deterioration, or increased dependency they would experience during that period due to a terminal illness or a debilitating condition. For these people, the right to opt to die painlessly, simply, and with dignity at the time and place of their choosing is paramount, and in recent years they have taken steps to secure that right. Their convictions have given rise to the Hemlock Society, the passage of an Oregon referendum authorizing physician-assisted suicide, and the work of Dr. Jack Kevorkian, who has personally assisted in the suicide of 20 people as of December 1993 using two patient-activated devices he created himself. Society has rarely strongly opposed the exercise of this "right;" indeed, while 28 states currently have laws declaring assistance in suicide a crime, no physician has been convicted for aiding in a suicide, and conviction of other types of suicide assistants has been sporadic at best. On the other hand, Michigan did ultimately prohibit physician-assisted suicide (PAS) in order to legally stop Dr. Kevorkian, and an injunction has prohibited enforcement of Oregon's referendum pending the resolution of constitutional challenges.